## Facts

- Rockford Map Publishers, Inc. created and sold rural county plat maps depicting parcel location, size, and ownership, derived from aerial photographs and courthouse title records.
- For Ford County, Illinois, Rockford traced topographical features, drew township/section lines, and converted deed legal descriptions into parcel boundaries with owner names.
- Rockford produced an original Ford County map and multiple later revisions; copyrights for several revisions, including the 1983 edition, were registered.
- Updating the Ford County map required about 14 hours of courthouse research; creating a new map required about 40–45 hours.
- Directory Service Company of Colorado, Inc., a competitor, made its Ford County product by enlarging Rockford’s maps and directing its agent, Frances A. Anderson, to verify and mark Rockford’s depictions against courthouse records, correcting errors on the enlarged copies.
- Rockford suspected copying after finding that deliberate small errors embedded in Rockford’s maps reappeared in Directory’s maps.
- Rockford sued for copyright infringement; the district court found infringement, awarded statutory damages and attorney’s fees, and enjoined further infringing use.
- Directory and Anderson appealed, arguing primarily that Rockford’s maps lacked the originality required for copyright protection.

## Issues

1. Whether a plat map depicting factual information from public records satisfies copyright’s originality requirement as a protectable compilation or expression.
2. Whether using a competitor’s copyrighted map as a worksheet/template to verify and correct public-record facts constitutes actionable copying.
3. Whether the district court’s injunctive relief, statutory damages, and attorney’s fees were proper on the record.

## Decision

- The Seventh Circuit affirmed the judgment for Rockford.
- The court held Rockford’s plat maps were copyrightable because they reflected independent effort and minimally creative choices in compiling and graphically expressing public-record information.
- The court held Directory infringed by copying Rockford’s maps and using them as the foundation for its own map, rather than independently translating legal descriptions into a new cartographic work.
- The court upheld the injunction, statutory damages, and attorney’s fees.

## Legal Principles

- Facts and public-domain data are not protected by copyright, but an author’s original selection, coordination, arrangement, and expressive presentation of those facts can be protected.
- Originality is a low threshold requiring independent creation and a minimal degree of creativity; it does not require novelty or invention.
- In maps derived from public records, originality may lie in the compiler’s judgment in interpreting textual legal descriptions and converting them into a coherent visual depiction.
- Protection for factual compilations may be limited, but it bars substantial appropriation that substitutes for independent compilation and expression.
- A competitor may obtain the same facts from the underlying records and create its own map, but may not use the copyrighted map as a detailed template that displaces the need for independent work.
- Evidence that distinctive embedded errors reappear in the accused work supports an inference of copying.

## Conclusion

The Seventh Circuit held that Rockford’s plat maps met the minimal originality requirement as protectable expressions of factual land-title information and that Directory’s practice of enlarging and using Rockford’s maps as verification worksheets constituted infringement, warranting injunctive relief and statutory remedies.


Rockford Map Publishers, Inc. v. Directory Service Co. of Colo., Inc., 768 F.2d 145 (7th Cir. 1985)